United States securities and exchange commission logo
April 14, 2021
Michele Allen
Chief Financial Officer
WYNDHAM HOTELS & RESORTS, INC.
22 Sylvan Way
Parsippany, NJ. 07054
Re: WYNDHAM HOTELS &
RESORTS, INC.
Form 10-K for the
year ended December 31, 2020
File No. 001-38432
Dear Ms. Allen:
We have reviewed your filing and have the following comments. In
some of our
comments, we may ask you to provide us with information so we may better
understand your
disclosure.
Please respond to these comments within ten business days by
providing the requested
information or advise us as soon as possible when you will respond. If
you do not believe our
comments apply to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to these comments, we may have additional comments.
Form 10-K for the year ended December 31, 2020
Critical Accounting Estimates and Policies
Impairment of Long Lived Assets, page 42
1. Please expand your
disclosures to identify the number of reporting units where goodwill is
allocated and tested
for impairment. Additionally, please indicate whether the fair value
substantially exceeds
book value for all reporting units. If the fair value of any reporting
unit does not
substantially exceed book value, please identify the reporting unit and
provide the following:
the percentage by
which fair value exceeded carrying value at the date of the most recent
test;
the amount of
goodwill allocated to the reporting unit;
a more detailed
description of the methods and key assumptions used and how the key
assumptions were
determined;
a discussion of the
degree of uncertainty associated with the assumptions; and
Michele Allen
WYNDHAM HOTELS & RESORTS, INC.
April 14, 2021
Page 2
a description of potential events and/or changes in circumstances
that could reasonably
be expected to negatively affect the key assumptions.
Please refer to Item 303(a)(3)(ii) of Regulation S-K and Section V of
SEC Release No.
34-48960.
5. Accounts Receivable, page F-20
2. We note that the provisions for the allowance for doubtful accounts
was $37 million, $16
million and $8 million for each of the fiscal years 2020, 2019 and
2018, respectively.
Please tell us more about the factors that led to the significant
increase in the
provision recognized during fiscal year 2020. Please ensure that the
Company s MD&A
disclosures fully address the facts and circumstances that drove the
change and whether
the disproportionate fluctuations in trends are expected to recur. See
Item 303(a)(3)(i) and
(ii) of Regulation S-K.
We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.
You may contact Ameen Hamady at 202-551-3891 or Shannon Menjivar at
202-551-
3856 if you have any questions.
FirstName LastNameMichele Allen Sincerely,
Comapany NameWYNDHAM HOTELS & RESORTS, INC.
Division of Corporation Finance
April 14, 2021 Page 2 Office of Real Estate & Construction
FirstName LastName